Continuity of Interest in Transfer of Target Assets After Qualified Stock Purchase of Target

Короткий зміст

This document prescribes final regulations under section 338 of the Internal Revenue Code regarding the transfer of target assets to the purchasing corporation or another member of the same affiliated group as the purchasing corporation after a qualified stock purchase (QSP) of target stock, if a section 338 election is not made. These regulations provide guidance to parties to such transfers.